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Your bank’s UDAAP risk profile, based on its size, products and services, location, etc, differs from that of any other bank so the solution does not come in a one-size fits all. This webinar will address the UDAAP risks we likely are all experiencing and provide a list of controls that will help mitigate those risks to a level that will allow your Compliance Officer, Senior Management and Board to sleep a little better. All UDAAP findings can be tied back to a few root causes that were likely avoidable.
Banking examination manuals for all regulatory agencies repeatedly point out that banks are expected to be aware of the most significant compliance risks to the bank, to consumers and to their customers. Folks – UDAAP likely is Public Enemy #1. Let’s identify those risks and get those controls in place now before your regulatory and reputation risk increase.
This recording will identify regulatory guidance that is available for this topic as well as findings from recent enforcement actions.
Examiner expectations, and enforcement actions, in this area are increasing and many of the recent enforcements actions have gone right for the UDAAP jugular without showing any violations of consumer affairs laws and regulations. A UDAAP Risk Assessment, much like a Compliance Management Program Risk Assessment or a Fair Lending Risk Assessment is not a regulatory requirement but there are a number of banks which now wish they had conducted one before being on the receiving end of an enforcement action and the likely Civil Monetary Penalty and regulatory downgrade.
UDAAP potential risk lurks in every corner of your bank and every bank that has run into a UDAAP enforcement action likely has been conducting business as usual for years without a word from its regulatory agencies until the fat lady started singing. The regulators have repeatedly reminded us that a bank could have complied with every underlying law or regulation but there was still something deceptive, unfair, or misleading about some nuance of the product or service. This risk assessment is a necessary step in determining how to refine the bank’s Compliance Management Program into one that also identifies and minimizes UDAAP risks.
You’ll receive a detailed manual and PowerPoint slides that serve as a valuable resource long after the conclusion of the program which will serve as a vital resource in developing or enhancing the bank’s UDAAP program.
Upon completion of the program participants understand:
- Common UDAAP risks for most banks and some risks that may be more specific to your bank based on your products, services, delivery methods and size;
- Once the risks have been identified, the controls that need to be developed and how to go about putting those controls in place;
- How to more easily identify acts or practices within your bank that have been in place for years but which could now be deemed unfair, misleading or deceptive;
- How to use training and your consumer complaint program as your best defense against potential UDAAP problems; and
- Development of the framework from scoping to final report writing for this assessment.
The program is designed for Risk Officers, Compliance Officers, BSA Officers, Fair Lending Officers, Auditors, Management and supporting staff members.